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Declarations

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Declaration of personal interest is key area that requires careful attention within organisations. Indeed, the general declaration of personal financial interests’ provision stipulated in s75(4) of the Companies Act 71 of 2008, as amended (“the Companies Act”), reads:

“At any time, a director may disclose any personal financial interest in advance, by delivering to the board, or shareholders in the case of a company contemplated in subsection (3), a notice in writing setting out the nature and extent of that interest, to be used generally for the purposes of this section until changed or withdrawn by further written notice from that director.”

Similarly, Part 5.3, Principle 7, Practice 25 of the King IV Report on Corporate Governance™ for South Africa 2016 (“King IV™”) recommends that:

“Subject to legal provisions, each member of the governing body should submit to the governing body a declaration of all financial, economic and other interests held by the member and related parties at least annually or whenever there are significant changes.”

The recommendation to make a general disclosure of relevant interests as alluded to above is in addition to the recommendation for a specific declaration to be made at the beginning of each meeting of the governing body or its committees of any conflict of interest that a member of the governing body may have in respect of a matter on the agenda.

Conflicts of interest may arise where an individual’s personal or family interests and/or loyalties conflict with those of the organisation. As a general rule, no conflict between the personal interests of members of a governing body and the interests of the organisation which they serve should be allowed.

Where a potential conflict of interest cannot be avoided, it has to be managed in such a manner as to ensure that the interests of the organisation are at all times protected. It is for this reason that the law in certain instances as well as best practice recommendations call for disclosure of interest in any matter on the agenda of the governing body or any of its committees.

However, considering that a matter may not necessarily find its way onto the agenda of the governing body and/or its committees, it is recommended that each member of a governing body submits a general declaration of interests that could assist the organisation in identifying potential conflicts between its interests and that of the members of its governing body or parties related to such members.

It is worthwhile to also note that correctly managing a conflict of interest could be of value and assistance to a member of the governing body wishing to rely on the business judgement rule as part of his defense in the event of legal action being taken against him in his capacity as a member of the governing body.

Declarations assists clients with the Conflict of Interest management process within their organisations by enabling their staff to make general declarations. Depending on the client configuration, employees are able to declare any of the following using the web browser on the device of their choice:

  • Gifts and Hospitality given and received
  • Personal Investments in listed equities or brokerage accounts
  • Ownership Interests in other organisations
  • Non-Commercial Interests
  • Close Personal Relationships with related parties (internal employees or external people)
  • Additional work interests and Personal Commercial Activity
  • Directorships
  • Trusts

Central Risk Management are able to configure the system to their organisation’s policies and procedures. In this way, client organisations have the freedom to decide what must be tracked and then configure the routing and approval rules for each action. They can also:

  • Build Watch Lists and Prohibited Entity Lists to enable users to proactively identify conflicts as the information is being recorded.
  • Capture details of related people and quickly identify Politically Exposed Persons
  • Review all declarations made (even those that may have been deleted) and have access to a detailed log file.
  • Quickly review and approve declarations or escalate to individuals for approval.
  • Capture declarations on behalf of other users using the Proxy function. (Users still have the ability to approve declarations made by proxy).

Key persons within the client organisation (Line Managers and Risk Cluster Managers) are also able to receive alerts and requests for approval based on the specific configuration.


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Change Log

7 June 2019 - v2.0.0

  • Modified the configuration screen so that admins can add user guidance for gifts and hospitality
  • Pull client definitions for risk manager, line manager and central risk management to the drop down lists on the configuration screen
  • Corrected error on the HELP screen to show email address and not username

21 June 2019 - v2.0.1

  • Changed labels from “Last valued date” to “Date”
  • Changed labels from “Decision” to “Status” and included 6 different status indicators and changed labels on buttons in the approval screen from “Record Decision” to “Save”

28 June 2019 - v2.0.2

  • Enhanced notifications and emails with additional user/declaration data
  • Refined reports to display additional details in expander nodes and primary data rows
  • Administrator commentary for Organisations and ability to FLAG organisation (not Watch List or Prohibited List)
  • Allow risk management to change the security type on investment approval modal
  • Report that shows all items where “I” was the last person to review/action the item
  • Moved “Completed” status option to bottom of all approval drop-downs
  • On all approval/edit modals - create a list of comments that can be added to by reviewers
  • Log the forward/approval request to the log file
  • Bulk Approvals - Added option to mark as COMPLETE
  • Greatly enhanced personal document management (e.g. Adding attachments when adding/editing a declaration and then displaying these in the “My Documents” list - with links to the actual declaration item.)

2 August 2019 - v2.0.3

  • Changes to review/approval process with enhanced UI for approver detail screens
  • Enhanced Task Management and reveres integration to core tasks module

9 August 2019 - v2.0.4

  • Reporting on persons and Financial Oversight role
  • Status tracking when passing back to user
  • Opening all content in the same window
  • Fixed issue with drop down lists in modals

16 August 2019 - v2.0.5

  • Integrated Hangfire for better user experience when emailing and processing large data sets
  • Changed labels on external relationships to “friendlier terms”
  • Removed motivation boxes for approval on Internal and External Relationships

28 August 2019 - v2.0.6

  • Updates to select lists to allow for upgrade on Select2 handlers
  • Associate persons with organisations in the gifting module
  • Better file handler for uploading PDF files
  • Split identification of “watch” and “prohibited” lists between persons and organisations where these are displayed in the same data grid
  • Enhancements to the “create client” modal

4 October 2019 - v2.0.7

  • Improved CSRF protection
  • Enhanced file upload and user interaction on file management
  • Improvements to the Administrator/Help documents upload/display

11 October 2019 - v2.0.8

  • Added investment breaches option to the investment add/edit modals
  • Added ability to link documents uploaded in the master documents screen to individual declaration items
  • Linking persons to organisations for all declaration types where persons are involved

25 October 2019 - v2.0.9

  • Added WYSIWIG Editor to all declaration cards
  • Addressed reviewer forwarding issue when user edits item after initial submission

3 January 2020 - v2.0.10

  • Added ability for users to add fellow employees to “Ownership Interests” and “Non-Commercial Interests”
  • Enhanced document handling for uploads
  • Cleaned up the user help interface

25 March 2020 - v2.0.11

  • Enhancements to the user interface (alert boxes)
  • Added item descriptor (usually organisation name) to all the “Approval Request” reports
  • Added a check box to every declaration type modal that enables the user to click to acknowledge acceptance of any terms and conditions applicable to that declaration item. This field is not compulsory.
  • Added additional user guidance to the ownership modals to remind users that the details of the declaration are kept private BUT that they should take care with what they type into the Organisation Name field as all users can see those details.

2 April 2020 - v2.0.12

  • Enhanced filtering and date management
  • Removed “Export to PDF” on data grids
  • Client-specific change for KPMG: Added ability record Business Relationships

10 April 2020 - v2.0.13

  • Changed configuration page so that the administrator can decide which declaration types need acceptance of Terms and Conditions from users
  • Added icons to configuration page and tidied up the layout
  • Added procedure to reset session variables from the configuration page when items are changed by the administrator

17 April 2020 - v2.0.14

  • Changes to the “Approval Requests” report to show age since the item was logged and to show how many times the items has been forward for review by others
  • Changes to the Approval Card on the Declaration Item screen enabling a user to “Comment”, “Send an FYI”, “Record a Decision” or “Forward to another reviewer”
  • Add user guidance on the Approval card to catch items where the reviewer has changed but the review clicks a link previously received in an email requesting them to review the item
  • Added functionality and report for the sending, receipt and acknowledgement of FYIs
  • Enhancements to the Activity Log to record sending and acknowledgement of FYIs
  • Added report for administrators to view all FYI alerts sent and acknowledged
  • Added colour coding on the Review Items screen for the Approval Decision
  • Added the ability for reviewer to indicate that they consulted with someone else when making the approval decision.
premiumapps/declarations.txt · Last modified: 2020/04/18 11:00 by admin